SI9 Schedule of duties for Certifiers
by Bregs Blog admin team
SI.9 Schedule of duties for Certifiers – do we need to re-evaluate costs?
Following on from comments received on our “SI.9 costs for a typical house” piece, we have compiled the following ‘schedule of duties for SI.9’. This incorporates inputs from from a number of specialist Design Certifiers (DC) and Assigned Certifiers (AC) on the new duties required under SI.9. At time of writing we have not seen a detailed schedule of services for DC/AC by the representative bodies for competent professionals (SCSI, ACEI or RIAI).
This is a preliminary list. If any readers have comments or additional duties they feel should be included also please send your comment into us here.
Additional Duties for SI.9 (a non-exhaustive schedule of services):
1. Design Stage: pre-commencement (separate DC/AC appointments may mean some duplication by DC/AC):
- Time required to audit designs (review of all drawings: architects, services engineers, structural and other specialist designed components, glazing etc.);
- Inspect design competence of project teams (review qualifications, experience, design qualifications; request, inspect and record professional indemnity insurances etc);
- Inspect design competence of project sub-contractor designers and/or specialist suppliers and designers, request, inspect and record professional indemnity insurances etc);
- Identify gaps in competence of design team and tender for specialist ancillary certifiers or testers;
- Request, inspect and record Professional Indemnity Insurances from suggested suppliers and manufacturers;
- Set up archive for documentation;
- Time needed to integrate BCAR requirements in tender and contract packages
- Statements relating to Part D compliance, on-site supervision and inspection, completion stage
2. Lodgment Stage: commencement (by AC):
- Complete and lodge commencement notice information (number of hours to lodge documentation under the BCMS);
- Collate design inputs, drawings, specifications and certificates from professional ancillary certifiers, specialist sub-contractors and suppliers;
- Parts A-M compliance documentation and review (including specialist ancillary certifier Part L inputs);
- Complete and lodge job-specific inspection plans and other required documentation;
- Specific recommendations for contract documents relating to Part D compliance, on-site supervision and inspection, completion stage;
- Time required to deal with invalid commencement notices;
- Duplicate commencement documentation may be required for multiple phases (to be clarified by Law Society and Department).
3. Site Stage (by AC and DC if separate appointments):
- Mininum suggested number of 12 site inspections in draft code of practice now issued by DECLG (more if RIAI and ACEI CPD recommended timescales are followed);
- Ongoing assembly and recording of all paperwork associated with part D compliance (CPR 2013 requires statements of performance and CE marks for all material used);
- Attendance at bi-monthly site meetings as required and ongoing review (separate to inspections- unclear if separate DC inspections required)- inspect and record key stages of all structural items, M & E installations, key fabric stages and component installations etc.
- Review of any changes to design that impact on building regulations at site meetings;
- Interim Part A-M audits by AC and uploading of any specification changes that affect Part A-M performance;
- Uploading by DC of any changes on-site that alter design certificate in advance of commencement of the particular phase of work involved (unclear at present how to complete this with BCMS)
- Ongoing input to be monitored by AC relating to Part D compliance, on-site materials inspection and collating CE information and statements of performance for all materials and components, completion stage documentation, sub-contractors’ inputs etc.
- Note: For “Design and Build” and public-sector projects specific clauses may be required by DC and AC’s to exclude time needed to audit ‘value engineering’ exercises as projects proceed- it may be more appropriate to suggest time charges for process that are undefined at outset.
- There needs to be an ‘get-out’ clause in a Certifier’s appointments to facilitate resignation by from project. This may be required if an owner or separate design team refuses to reverse non-compliant work at site stage. It is unclear whether DC/AC has a responsibility to inform BCO of any non-compliant works in this scenario, and how this could affect outstanding payments for services.
4. Completion Stage (By AC):
- Completion stage- no online system as yet but initial completions indicate over 150 individual certificates need to be assembled for a mid-sized project,
- lodgment of all relevant documentation(to be confirmed by Building Control Code of Practice due September 2014) 3-5 weeks in advance of practical completion, secondary lodgments to facilitate occupation on the date of practical completion as required (there may be some duplication here if uploading unsigned forms and then signed forms etc).
- Additional time to deal with with Building Control invalidations (completion stage);
- Re-submission of completion documentation (as required)
- Conveyancing issues, phasing/part-completion issues, additional documentation that may be required etc. Duplicate completion documentation may be required for multiple phases.
- Completion of archive with all relevant Part D record of materials, ancillary certificates, sub-contractor design certificates, specialist sub-contractor inspection plans, forms etc.
5. Exclusions: Other costs associated with SI.9 that may affect professional and building costs-
- increased insurance premiums
- defensive specifications
- contractor costs etc. (self-builder additional cost)
A previous post put the additional SI.9 costs for a typical house at €20k for standard procurement models (main contractor appointed) and over €40k for self-build projects (see LINK). One can only speculate as to the effect these additional costs and lack of industry readiness may have on the FDI and SME sector, two key engines for growth.
A speaker at the recent representative body for architects (RIAI) EGM on 12th August called for a full Regulatory Impact Assessment on the new regulations.
The Department of the Environment should consider commissioning an independent review of the cost impact of SI.9. It is clear that Departmental advisors may have underestimated the scope of services to be provided when acting as Design Certifier and Assigned Certifier, and that the former Minister’s estimates of €1000-€3000 for such services on a private dwelling project would go nowhere towards the real cost to housing, or other non-residential projects.
It might be opportune for the new Minister to undertake a more in-depth independent review of the costs at this point, given the urgent need to kick-start housing and reduce costs and delays on FDI and SME projects.
Other posts of interest: